Weis v. Commissioner
United States Tax Court
F, a limited partnership, purchased a farm in 1981 for a contract price in the amount of $ 870,000. Pursuant to the contract, F was required to pay $ 205,000 to the seller upon closing. The remaining balance of the contract price, $ 665,000, was to be paid by F in five minimum annual installments of $ 11,500 plus a balloon payment due 6 years after the closing date of the outstanding balance remaining due under the contract. The contract did not provide for interest.
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F, a limited partnership, purchased a farm in 1981 for a contract price in the amount of $ 870,000. Pursuant to the contract, F was required to pay $ 205,000 to the seller upon closing. The remaining balance of the contract price, $ 665,000, was to be paid by F in five minimum annual installments of $ 11,500 plus a balloon payment due 6 years after the closing date of the outstanding balance remaining due under the contract. The contract did not provide for interest. Held: The amount of interest imputed under the contract, and the rate at which it is to be deducted, is governed by sec. 483.…
1Opinion of the Court
OPINION
FAY, Judge:
Respondent determined deficiencies in and additions to petitioners’ Federal income tax as follows: Docket No. 26336-88, Thomas J. and Gloria J. Weis:
Additions to tax
Year Deficiency Sec. 6653(a)(1) 2 Sec. 6653(a)(2) Sec. 6659 Sec. 6661
1982 $6,855 $343 * $558 $1,249
1983 5,836 292 * 457 1,078
Docket No. 27525-88, Pat Savaiano:
Addition to tax
Year Deficiency Sec. 6659
1983 $4,527 $387.60
Docket No. 27526-88, Pat Savaiano and Carol Savaiano:
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1982 $1,324 $66.20 * $203.40
Docket No. 27527-88, Pat Savaiano and Ann M.…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Marcello v. CommissionerUnited States Tax Court · 1964
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
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